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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
May 2013:
Grants Management:
Improved Planning, Coordination, and Communication Needed to
Strengthen Reform Efforts:
GAO-13-383:
GAO Highlights:
Highlights of GAO-13-383, a report to congressional requesters.
Why GAO Did This Study:
GAO has previously identified several management challenges that have
hindered grants management reform efforts. GAO was asked to review
recent federal grants management reform efforts. GAO reviewed (1) what
OMB and other federal grants governance bodies have done since the
passage of P.L. 106-107 to reform grants management processes, and (2)
what actions, if any, have been taken to address what GAO has found to
be persistent management challenges. GAO reviewed relevant
legislation, OMB circulars and guidance, action plans of interagency
councils responsible for overseeing grants management reforms, and
previous GAO work and other literature on grants management reforms.
GAO also reviewed its previous work on collaborative mechanisms and
management consolidation efforts. GAO also interviewed officials from
OMB, grant-making agencies, and associations representing a variety of
grantee types.
What GAO Found:
In the past 14 years, since the passage of the Federal Financial
Assistance Management Improvement Act of 1999 (P.L. 106-107), there
has been a series of legislative- and executive-sponsored initiatives
aimed at reforming aspects of the grants management life cycle.
Recently, a new grants reform governance body, the Council on
Financial Assistance Reform (COFAR), replaced two former federal
boards—-the Grants Policy Committee (GPC) and Grants Executive Board
(GEB). The Office of Management and Budget (OMB) created COFAR and
charged it with identifying emerging issues, challenges, and
opportunities in grants management and policy and providing
recommendations to OMB on policies and actions to improve grants
administration.
In addition to this new governance structure, OMB and other entities
involved with federal grants management are overseeing several ongoing
reform initiatives intended to address the challenges grantees
encounter throughout the grants life cycle. These initiatives include
consolidating and revising grants management circulars, simplifying
the pre-award phase, promoting shared information technology (IT)
solutions such as the development of shared end-to-end grants
management systems, and improving the timeliness of grant close out
and reducing undisbursed balances. Management and coordination
challenges could hinder the progress of some of these initiatives. For
example, although promoting shared IT solutions for grants management—-
an original goal of P.L. 106-107—-remains a priority, there has been
uncertainty regarding the status of this initiative and future plans
for it. The lead agency for this initiative changed several times
since 2012, and it has been unclear at times whether promoting shared
IT systems for grants management would continue to be a priority, and
if so, which agency was in charge. After receiving GAO’s draft report
for review, OMB issued a “Controller Alert” on April 29, 2013,
announcing that the Department of the Treasury would lead efforts to
transform federal financial management by, among other things, relying
on common standards, shared services, and using state-of-the-art
technology.
Although COFAR has recently identified several high-level priority
goals for 2013 through 2015, it faces some of the same management
challenges identified in previous GAO reports on grants management,
such as the lack of a comprehensive plan for implementing reforms,
confusion over roles and responsibilities among grants governance
bodies, and inconsistent communication and outreach to the grantee
community. COFAR has not yet released to the public an implementation
plan that includes key elements such as performance targets and goal
leaders for each goal, and mechanisms to monitor, evaluate, and report
on progress made toward stated goals. Furthermore, agencies involved
with current grants management reforms are not always clear on their
roles and responsibilities for various streamlining initiatives which
may cause such initiatives to languish. Finally, GAO found that
members of the grant recipient community continue to voice concern
because they do not see a role for themselves as OMB and COFAR develop
priorities for reforming federal grants management. In the comments it
provided on April 29, 2013, OMB described actions it is taking to
address these challenges, such as using a more detailed project plan
internally and scheduling outreach events with federal partners and
members of the grantee community.
What GAO Recommends:
GAO recommends that the Director of OMB: (1) develop and make publicly
available an implementation schedule that includes performance
targets, goal leaders who can be held accountable for each goal, and
mechanisms to monitor, evaluate, and report on results; (2) clarify
the roles and responsibilities for various streamlining initiatives;
and (3) develop an effective two-way communication strategy with
relevant stakeholders. OMB generally concurred with our
recommendations and provided additional and updated information, which
was incorporated into the report as appropriate.
View [hyperlink, http://www.gao.gov/products/GAO-13-383]. For more
information, contact Stanley J. Czerwinski at (202) 512-6806 or
czerwinskis@gao.gov.
[End of section]
Contents:
Letter:
Background:
Process Initiatives Helped Reform Aspects of the Grants Management
Life Cycle, but Management and Coordination Challenges Could Hinder
Further Progress:
OMB and the Council on Financial Assistance Reform Face Persistent
Challenges in Reforming Federal Grants Management:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Table of Selected Grants Management Reforms:
Appendix III: Grants Management Line of Business Consortia Leads and
Customers as of January 2013:
Appendix IV: Comments from the Office of Management and Budget:
Appendix V: GAO Contact and Staff Acknowledgments:
Figures:
Figure 1: Grant Life Cycle for Federal Grant-Making Agencies and Grant
Recipients:
Figure 2: Timeline of Selected Grants Management Reforms:
Abbreviations:
ACF: Administration for Children and Families:
COFAR: Council on Financial Assistance Reform:
FIT: Department of the Treasury's Office of Financial Innovation and
Transformation:
FDP: Federal Demonstration Partnership:
FFATA: Federal Funding Accountability and Transparency Act of 2006:
FMLOB: Financial Management Line of Business:
GATB: Government Accountability and Transparency Board:
GEB: Grants Executive Board:
GMLOB: Grants Management Line of Business:
GPC: Grants Policy Committee:
GSA: General Services Administration:
HHS: Health and Human Services:
IT: Information Technology:
OMB: Office of Management and Budget:
NSF: National Science Foundation:
PMO: Program Management Office:
PMS: Payment Management System:
Recovery Board: Recovery Accountability and Transparency Board:
[End of section]
United States Government Accountability Office:
GAO:
441 G St. N.W.
Washington, DC 20548:
May 23, 2013:
The Honorable Thomas R. Carper:
Chairman:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Tom Coburn, M.D.
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Claire McCaskill:
Chairman:
Subcommittee on Financial and Contracting Oversight:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
Grants play a significant role in implementing and funding federal
programs including medical services, nutrition programs, and housing
assistance for the sick and economically disadvantaged; financial aid
for more than 14 million postsecondary students; and funding and
maintenance of our nation's highways, bridges, and mass transit
system.[Footnote 1] Federal outlays for grants to state and local
governments steadily increased from $91 billion in fiscal year 1980
(about $221 billion in 2011 constant dollars) to approximately $545
billion in fiscal year 2012.[Footnote 2] Over time, growth in the
numbers of grant programs to state and local governments and their
level of funding has contributed to greater diversity and complexity
in the federal grants management processes. Multiple reporting systems
and data requirements associated with administering these federal
grants have increased the burden and cost of grants management for
agencies and grantees.
Efforts to streamline federal grants management have been under way
for well over a decade. Concerned that aspects of the grants
management process lacked coordination among agencies and consistency
with application and reporting requirements, Congress passed the
Federal Financial Assistance Management Improvement Act of 1999,
commonly referred to by the grants community as P.L. 106-107.[Footnote
3] Since the enactment of P.L. 106-107, the federal government has
taken a number of additional steps to reform government-wide grants
management to achieve greater efficiency and transparency. While P.L.
106-107 sunsetted in 2007, a number of reform initiatives continue,
and new initiatives have been put into place. Our previous work
described many of these initiatives and the related challenges--the
lack of a comprehensive plan for implementing reforms, confusion over
roles and responsibilities among grants governance bodies, and
inconsistent communication and outreach to the grantee community--that
have undermined the government's ability to simplify grants management
processes, reduce unnecessary burden on applicants, grantees, and
federal agencies, and improve delivery of services to the public.
[Footnote 4]
You asked us to examine federal grants management reform efforts. To
accomplish this, we reviewed (1) what the Office of Management and
Budget (OMB) and other federal grants governance bodies have done
since the passage of P.L. 106-107 in 1999 to reform grants management
processes and reduce unnecessary burdens on applicants, grantees, and
federal agencies; and (2) what actions, if any, have been taken to
address what we have found to be persistent management challenges.
To address these objectives, we reviewed P.L. 106-107, relevant OMB
circulars and guidance, and action plans created by former and current
interagency councils with responsibility for overseeing grants
management reforms.[Footnote 5] We interviewed officials from the
Office of Management and Budget (OMB) who are involved with developing
and implementing government-wide grants management policy; officials
at the three agencies that served as consortia leads for the 2004 to
2012 Grants Management Line of Business (GMLOB) e-government
initiative: the National Science Foundation (NSF), Department of
Health and Human Services (HHS), and the Department of
Education(Education); and officials at the General Services
Administration (GSA), the agency that managed the Financial Management
Line of Business (FMLOB) e-government initiative in 2012. To capture
the perspective of grantor agencies, we spoke to officials from HHS,
NSF, and Education in their grant-making and administration
capacities. To understand grantee perspectives, we interviewed
officials from grantee associations that represent a variety of
grantee types including state and local governments, nonprofit
organizations, and universities.[Footnote 6] Finally, we reviewed our
previous work on grants management initiatives and the related
challenges that have undermined the government's ability to simplify
grants management processes, reduce unnecessary burden on applicants,
grantees, and federal agencies, and improve delivery of services to
the public. We also reviewed our previous work on collaborative
mechanisms and management consolidation efforts. For more information
on objectives, scope and methodology, see appendix I.
We conducted this performance audit from July 2012 to May 2013 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
Background:
Grant Life Cycle and Reporting Requirements:
While there is substantial variation among grant types, competitively
awarded federal grants generally follow a life cycle comprising
various stages--pre-award (announcement and application), award,
implementation, and closeout--as seen in figure 1. Once a grant
program is established through legislation, which may specify
particular objectives, eligibility, and other requirements, a grant-
making agency may impose additional requirements on recipients. For
competitive grant programs, the public is notified of the grant
opportunity through an announcement, and potential recipients must
submit applications for agency review. In the award stage, the agency
identifies successful applicants or legislatively defined grant
recipients and awards funding. The implementation stage includes
payment processing, agency monitoring, and recipient reporting, which
may include financial and performance information. The closeout phase
includes preparation of final reports, financial reconciliation, and
any required accounting for property. Audits may occur multiple times
during the life cycle of the grant and after closeout.
Figure 1: Grant Life Cycle for Federal Grant-Making Agencies and Grant
Recipients:
[Refer to PDF for image: process illustration]
Stage: 1: Preaward Stage;
Agency Process:
* Announce opportunity:
- Provide administrative and technical support;
* Receive application:
- Authenticate applicant, apply business rules, and ensure
administrative compliance;
* Review and decision:
- Conduct reviews (administrative, budget, policy, merit, business,
application, certifications, and assurances).
Recipient Process:
* Find opportunity:
- Identify potential opportunity;
- Develop proposal;
* Submit application:
- Submit application package for competitive grant or other pre-award
documents for noncompetitive grant;
* Status review:
- Check status of application.
Stage: 2: Award Stage;
Agency Process:
* Award notification:
- Notify the grantee and Congress and publicly announce the award;
Recipient Process:
* Receive notification of award:
- Complete award acceptance documents, if required.
Stage: 3: Implementation Stage;
Agency Process:
* Disburse payment:
- Process payments to recipient;
* Management and oversight:
- Conduct site visits and review recipient reports;
Recipient Process:
* Request and receive payment:
- Request disbursement of grant funds;
* Perform grant requirements and submit reports:
- Comply with award terms and conditions, including general
administrative requirements and cost principles;
- Submit appropriate financial, performance, and other reports.
Stage: 4: Closeout Stage;
Agency Process:
* Closeout:
- Review and reconcile final audit and other reports;
Recipient Process:
* Closeout:
- Submit final audit and other reports, as required.
Source: GAO.
[End of figure]
Federal agencies do not have inherent authority to enter into grant
agreements without affirmative legislative authorization. In
authorizing grant programs, federal laws identify the types of
activities that can be funded and the purposes to be accomplished
through the funding. Legislation establishing a grant program
frequently will define the program objectives and leave the
administering agency to fill in the details by regulation.
Adding to the complexity of grants management, grant programs are
typically subject to a wide range of accountability requirements
(under their authorizing legislation or appropriation) and
implementing regulations, which are intended to ensure that funding is
spent for its intended purpose. Congress may also impose increased
reporting and oversight requirements on grant-making agencies and
recipients. In addition, grant programs are subject to crosscutting
requirements applicable to most assistance programs. OMB is
responsible for developing government-wide policies to ensure that
grants are managed properly and that grant funds are spent in
accordance with applicable laws and regulations. For decades, OMB has
published guidance in various circulars to aid grant-making agencies
with such subjects as audit and record keeping and the allowability of
costs.[Footnote 7]
Federal Grants Management Reforms:
In the past 14 years, since the passage of P.L. 106-107, there has
been a series of legislative-and executive-sponsored initiatives aimed
at simplifying aspects of the grants management life cycle; minimizing
the administrative burden for grantees, particularly those that obtain
grants from multiple federal agencies; and ensuring accountability by
improving the transparency of the federal grants life cycle. See
figure 2 for more information.
Figure 2: Timeline of Selected Grants Management Reforms:
[Refer to PDF for image: interactive timeline graphic]
Directions: Mouseover the following reforms on the following timeline
for more information.
For text version of this graphic, go to appendix II.
Source: GAO.
[End of figure]
Process Initiatives Helped Reform Aspects of the Grants Management
Life Cycle, but Management and Coordination Challenges Could Hinder
Further Progress:
Since the passage of P.L. 106-107, OMB and other entities involved
with federal grants management have overseen several ongoing
initiatives intended to address the challenges grantees encounter
throughout the grants life cycle. These initiatives include
consolidating and revising grants management circulars, simplifying
the pre-award phase, promoting shared IT solutions for grants
management, and improving the timeliness of grant closeout and
reducing undisbursed balances. However, management and coordination
challenges could hinder the progress of some of these initiatives.
Increasing Efficiency and Effectiveness of Grant Programs by
Consolidating and Revising Guidance in Grant Management Circulars:
As part of the effort to implement P.L. 106-107, OMB began an effort
in 2003 to (1) consolidate its government-wide grants guidance, which
was located in seven separate OMB circulars and policy documents, into
a single title in the Code of Federal Regulations, and (2) establish a
centralized location for grant-making agencies to publish their
government-wide grant regulations.[Footnote 8] The purpose of this
effort was to make it easier for grantees to find and use the
information in the OMB circulars and agencies' grant regulations by
creating a central point for all grantees to locate all government-
wide grants requirements. As of March 2013, OMB has completed
revisions on guidance related to two areas--suspension and debarment
and drug-free workplace.[Footnote 9] All grant-making agencies have
relocated their suspension and debarment regulations to one title of
the Code of Federal Regulations and some have relocated the drug-free
workplace regulations.
OMB has also been consulting with stakeholders to evaluate potential
reforms in federal grant policies contained in the multiple grant
circulars.[Footnote 10] As a first step, in February 2012, OMB
published an advanced notice of proposed guidance detailing a series
of reform ideas that would standardize information collection across
agencies, adopt a risk-based model for single audits (annual audits
required of nonfederal entities that expend more than $500,000 in
federal awards annually), and provide new administrative approaches
for determining and monitoring the allocation of federal funds.
[Footnote 11] After receiving more than 350 public comments on the
advanced notice of proposed guidance, OMB published its circular
reform proposal in February 2013 and plans to implement the reforms by
December 2013.[Footnote 12] OMB officials believe that once
implemented, these reforms have the potential to make grant programs
more efficient and effective by eliminating unnecessary and
duplicative requirements and strengthening the oversight of grant
dollars by focusing on areas such as eligibility, monitoring of
subrecipients, and adequate reporting.
Simplifying the Pre-Award Phase by Improving Grants.gov:
Launched in 2003, Grants.gov is a website the public can use to search
and apply for federal grant opportunities. Officials we spoke to from
associations representing state and local governments, universities,
and nonprofits praised Grants.gov. Many noted that it simplified the
pre-award stage by making it easier for applicants to search for and
identify federal grant funding opportunities. Specifically, one
organization said the site does an excellent job categorizing grants
by topic, making it easier for resource-constrained applicants that
may not have a professional grant writer to search for relevant grants.
However, grantee association officials also raised concerns about
aspects of the site. For example, although there is an OMB policy
directive establishing a standard format for federal funding
opportunity announcement requirements, grantee officials said that in
practice the lack of a standardized grants announcement can increase
their burden because extra time is required to determine eligibility
and other requirements.[Footnote 13] We have also reported that
persistent management challenges, such as a lack of performance
measures and communication with stakeholders and unclear roles and
responsibilities among the governance entities, have adversely
affected Grants.gov operations.[Footnote 14]
Since we first reported on these issues in July 2009, HHS has made
some progress to address these challenges and increase the
effectiveness and long-term viability of Grants.gov. Specifically, HHS
is taking steps to implement several of our prior recommendations. For
example, in 2012, the Program Management Office (PMO) adopted a
performance monitoring tool that currently monitors 22 technical
measures covering availability, usage, and performance. The PMO also
hired a communications director whose responsibilities include
outreach to stakeholders. The PMO reported that starting in fiscal
year 2013, HHS plans to more actively solicit input from grants
applicants on ways to enhance the site. While it is too soon to
determine the effectiveness of these reforms, tracking site
performance and developing an effective two-way communication strategy
to engage with stakeholders are practices which, if thoughtfully and
deliberately implemented, may address the challenges we identified.
Promoting Post-Award Shared Information Technology Solutions for
Grants Management:
Promoting shared information technology (IT) solutions for managing
grants--an original goal of P.L. 106-107 and the governance bodies
charged with implementing the legislation--could provide an additional
way to simplify post-award grants management activities by
consolidating the administration and management of grants across
agencies and potentially reducing the costs of multiple agencies
developing and maintaining grants management systems. However, it is
unclear whether promoting shared IT systems for grants management is
still a priority, and if so, which agency is in charge of this effort.
In 2004, OMB established the GMLOB to develop government-wide
solutions intended to support end-to-end grants management activities,
including shared grants management systems (which could include
modules for intake of applications, peer review, award, payment, and
performance monitoring and final closeout of the grant award). In
2005, OMB chose three agencies--the National Science Foundation (NSF),
the Administration for Children and Families within the Department of
Health and Human Services (HHS), and the Department of Education--to
develop grants management systems that they could provide for other
agencies. Currently, NSF operates Research.gov, which has one other
external agency customer that uses individual modules of the
Research.gov system; the Administration for Children and Families
operates GrantSolutions.gov, which services 17 government customers, 8
of which are HHS components; and Education operates G5, which has 13
customers all of which are Education components (see appendix III for
a list of NSF, HHS, and Education customers).
Since 2012, there has been uncertainty regarding the status of and
future plans for the operational elements of what was the GMLOB. OMB
folded GMLOB into the Financial Management Line of Business (FMLOB)--
an initiative focused on financial systems improvements--in 2012, and
initially announced the Treasury Department would be the managing
partner.[Footnote 15] Later, OMB informed us the General Services
Administration (GSA) would be the managing partner, but GSA officials
informed us they were only the managing partner of the FMLOB from June
to September 30, 2012. GSA officials also told us that according to
OMB officials, GSA would not be responsible for working with NSF, HHS,
or Education, or promoting shared service agreements for grants
management systems. As of March 2013, OMB had not publicly announced
who the managing partner of FMLOB would be for fiscal year 2013. After
receiving a draft copy of this report for its review and comment, OMB
issued a "Controller Alert" on April 29, 2013, announcing that, for
fiscal year 2013, the Department of the Treasury's Office of Financial
Innovation and Transformation (FIT) will serve as Managing Partner and
the Program Management Office for the FMLOB. OMB also highlighted the
Controller Alert in its comment letter to us, also dated April 29,
2013 (see appendix IV for OMB's letter).
In May 2012, OMB issued guidance directing agencies to find ways to
spend federal dollars on IT more efficiently to compensate for a 10
percent reduction in overall IT spending.[Footnote 16] The guidance
also directed agencies to propose how they would reinvest the savings
from proposed cuts to produce a favorable return on investments. One
of the strategies OMB had previously highlighted to reduce
duplication, improve collaboration, and eliminate waste across agency
boundaries was the Federal IT Shared Services Strategy, also referred
to as "Shared First," an effort to share common IT services across
agencies. The guidance did not specifically mention grants management
systems, and it is unclear whether OMB intends to encourage other
agencies to partner with NSF, HHS, and Education to continue sharing
services. In its April 29, 2013, Controller Alert, OMB stated that in
accordance with OMB's guidance on shared services, the Treasury's FIT
will "lead efforts to transform federal financial management, reduce
costs, increase transparency, and improve delivery of agencies'
missions by operating at scale, relying on common standards, shared
services, and using state-of-the-art technology."[Footnote 17]
However, OMB's Controller Alert did not address whether the roles of
NSF, HHS, and Education would change as a result of FIT's leadership
in this area.
Improving the Timeliness of Grant Closeout and Reducing Undisbursed
Balances at the End of the Grant Life Cycle:
As part of its efforts to improve grants management government-wide,
OMB has instructed agencies to improve the timeliness of their grant
closeout procedures. Once the grant's period of availability to the
grantee has expired, the grant can be closed out and the funds
deobligated by the awarding agency. Timely closeout helps to ensure
that grantees have met all financial and reporting requirements. It
also allows federal agencies to identify and redirect unused funds to
other projects and priorities as authorized or to return unspent
balances to the Department of the Treasury. In August 2008, we
reported that during calendar year 2006 about $1 billion in
undisbursed funding remained in expired grant accounts in the largest
civilian payment system for grants, the Payment Management System.
[Footnote 18] In a follow-up report issued in April 2012, we found
that at the end of fiscal year 2011 there was more than $794 million
in funding remaining in expired grant accounts.[Footnote 19] To
improve the timeliness of grant closeout, we recommended that OMB
instruct all executive departments and independent agencies to
annually track the amount of undisbursed grant funding remaining in
expired grant accounts and report on the status and resolution of the
undisbursed funding in their annual performance plan and annual
performance and accountability report. In response to our
recommendations, on July 24, 2012, the Controller of OMB issued a
"Controller Alert" to all federal chief financial officers instructing
agencies to take appropriate action to close out grants in a timely
manner. The alert provided strategies agencies should consider to
achieve this goal, including establishing annual or semiannual
performance targets for timely grant closeout, monitoring closeout
activity, and tracking progress in reducing closeout backlog.
OMB and the Council on Financial Assistance Reform Face Persistent
Challenges in Reforming Federal Grants Management:
OMB has taken actions to address persistent management challenges
identified in several of our reports issued from 2005 through 2011.
For example, in October 2011, OMB replaced the Grants Executive Board
(GEB) and Grants Policy Committee (GPC) with the Council on Financial
Assistance Reform (COFAR), an interagency council, and charged it with
providing policy-level leadership for the grants community and
implementing reforms to improve effectiveness and efficiency in
federal grants. Although COFAR has recently identified several high-
level priorities for 2013 to 2015, the council faces some of the same
challenges we previously identified, such as the lack of a
comprehensive plan for implementing reforms, confusion over roles and
responsibilities among grants governance bodies, and inconsistent
communication and outreach to the grantee community. Moreover, based
on recent reviews of collaborative mechanisms and management
consolidation efforts, we found that interagency councils benefit when
participants identify goals, devise a plan for reaching and achieving
those goals, clearly articulate roles and responsibilities, and
develop an effective two-way communication strategy with relevant
stakeholders.[Footnote 20],[Footnote 21]
COFAR Announced Grants Management Reform Goals, but Key Implementation
Elements Remain Undefined:
In a September 2012 report, we identified certain key features for
effective interagency collaborative efforts, including the importance
of identifying goals for short-and long-term outcomes. Identifying
goals can help decision makers reach a shared understanding of what
problems genuinely need to be fixed, how to balance differing
objectives, and what steps need to be taken to create not just short-
term advantages but long-term gains.[Footnote 22]
In February 2013, COFAR posted five priority goals for fiscal years
2013 to 2015 to the U.S. Chief Financial Officers Council website:
[Footnote 23]
1. Implement revised guidance to target risk and reduce administrative
burden.
2. Standardize federal agencies' business processes to streamline data
collections.
3. Provide public validated financial data that aligns spending
information with core financial accounting data in coordination with
the work of the GATB.
4. Ensure that federal agencies' grants professionals are highly
qualified.
5. Reduce the number of unclean audit opinions for grant recipients.
For each priority, COFAR identified proposed deliverables and
milestone dates for those deliverables. As of May 2013, COFAR had not
released to the public an implementation plan that includes other key
elements such as performance targets, mechanisms to monitor, evaluate,
and report on progress made towards stated goals, and goal leaders who
can be held accountable for those goals. Establishing implementation
goals and tracking progress toward those goals helps to pinpoint
performance shortfalls and suggest midcourse corrections, including
any needed adjustments to future goals and milestones. Reporting on
these activities can help key decision makers within the agencies, as
well as stakeholders, obtain feedback for improving both policy and
operational effectiveness.
In response to the draft report we provided for them to review, OMB
officials stated in their comment letter dated April 29, 2013, that
they used a more detailed internal project plan to monitor timelines
and roles and responsibilities. They acknowledged that more needs to
be done by pointing out that as the work of COFAR matured, the council
would be better able to articulate metrics that allowed for a more
thorough evaluation of whether the policy changes were having their
intended impacts. They added that the publicly-stated deliverables
were intended to leave room for further evolution of the right
approach for implementation. While we have not been able to assess or
validate OMB's newly provided information on COFAR's approach, we
believe a more detailed, publicly-available implementation plan that
will allow Congress and the public to better monitor the progress of
the reforms is needed.
Lack of Clearly Articulated Roles and Responsibilities Continues to Be
a Challenge:
We previously reported that when interagency councils clarify who will
do what, identify how to organize their joint and individual efforts,
and articulate steps for decision making, they enhance their ability
to work together and achieve results.[Footnote 24] In interviews with
federal grant management officials we were told that OMB and the
council do not always clearly articulate the roles and
responsibilities for various streamlining initiatives, plans for
future efforts, and means for engaging small grant-making agency
stakeholders and utilizing agency resources.
Agency officials involved with current grants management reforms told
us that the roles and responsibilities for various streamlining
initiatives are not always clear. For example, OMB designated Treasury
as the managing partner of the FMLOB initiative, then designated GSA
as the managing partner, but only for four months. As of March 2013,
OMB had not issued a subsequent announcement as to which agency would
take over the grants management related functions of FMLOB after GSA.
In the meantime, the former GMLOB consortia leads are unsure whether
promoting shared grants management systems is still a priority. As
previously mentioned, OMB's Controller Alert of April 29, 2013,
announced that Treasury's FIT office will serve as Managing Partner
and the Program Management Office for the FMLOB for fiscal year 2013.
However, the Controller Alert did not address whether the roles of
NSF, HHS, and Education would change as a result of FIT's leadership
in this area.
In addition to OMB, eight agencies are permanent members of COFAR.
COFAR also has a rotating member, currently NSF, which serves a two-
year term.[Footnote 25] Agency officials involved with COFAR told us
that the council is still determining the role of the rotating agency
and how COFAR will reach out to smaller grant-making agencies not on
the council. According to OMB officials, they are still working out
how to provide other agencies with a communication channel and the
opportunity to review and comment on proposed changes. In its April
29, 2013, comment letter, OMB acknowledged that the expectation was
that the rotating member would be able to represent the views of
smaller agencies and that there may be federal officials or agencies
that wish to be more involved or not fully aware of the all the
COFAR's work. OMB officials also stated that COFAR staff will help the
rotating agency gather input and feedback from the broader collection
of smaller agencies. OMB officials said incorporating the views of all
federal grant-making agencies was essential to the work of the COFAR
and that their strategy would continue to evolve over time, as it will
for engaging with nonfederal stakeholders.
Agency officials also told us that they are still trying to determine
how to bring together financial, policy, and IT staff, and incorporate
their areas of expertise into discussions on proposed policy and
program changes. One agency official noted this had been a challenge
with the previous grants management structure. She said that the GPC
focused on policy and the GEB focused on systems and technology
solutions and, even though there was some level of overlap among the
people staffing the two boards, a stronger connection was needed to
ensure that streamlining efforts included technology and policy
expertise. In their comment letter, OMB officials stated they made
repeated efforts to solicit the views of all federal agencies through
town hall meetings, formal circulation of draft policies for comment
prior to publication, and conference calls to share information on key
issues.
Grantee Stakeholders Continue to Report Limited Opportunities to
Provide Feedback on Grants Management Reforms:
We have noted that communication is not just "pushing the message
out," but should facilitate a two-way, honest exchange and allow for
feedback from relevant stakeholders.[Footnote 26] We previously
reported that grantees felt that the lack of opportunities to provide
timely feedback resulted in poor implementation and prioritization of
streamlining initiatives and limited grantees' use and understanding
of new functionality of electronic systems.[Footnote 27] For example,
grantees experienced problems stemming from policies and technologies
that were inconsistent with their business practices and caused
inefficiencies in their administration of grants.
Members of the grantee community told us they continue to have
concerns because they do not see a role for themselves as OMB and
COFAR develop priorities for reforming federal grants management. For
example, officials from the eight associations representing state and
local governments, universities, and nonprofit recipients told us that
outreach to grantees on proposed reforms continues to be inconsistent
or could be improved. Ten organizations representing state and local
officials, including some of the same organizations we interviewed,
submitted a letter to OMB after the creation of COFAR was announced,
expressing their disappointment that there would be no state or local
representation on the council.[Footnote 28] In the letter, the state
and local officials stated that formal engagement of all stakeholder
parties is necessary for success and that their exclusion from the
council undermined the important work of the council before it even
commenced.
OMB officials stated they are seeking different forums to engage with
members of the grantee community. Several association officials said
they appreciated that OMB reached out to them for comment before
proposing changes to OMB circulars. OMB and COFAR also hosted a
webinar in February 2013 to coincide with the circular reform
proposal, and invited representatives from grantee associations to
discuss their concerns and ask questions. In addition, following their
review of the draft report, OMB officials provided us with a list of
invitations for speaking engagements they have accepted since February
2013 as a snapshot of the types of engagements they participate in to
communicate with interested stakeholder groups.
While improved outreach to the broader grantee community is an ongoing
challenge, certain groups of grantees have established communication
channels with the federal government. These approaches could be a
useful model for COFAR to build upon with different grantee
communities. For example, we have previously reported that the
research community established avenues of communication with relevant
federal agencies through the Federal Demonstration Partnership (FDP),
a cooperative initiative of 10 agencies and over 90 research
institutions.[Footnote 29] Agency officials and members of the
research community continue to describe this partnership as an
effective model for promoting two-way communication. Officials from
the HHS Grants.gov PMO told us they solicit information and feedback
related to the functionality of Grants.gov through quarterly meetings
and open forum-type sessions with FDP members. According to these
officials, consistent communication with the FDP has enabled them to
survey the community and determine appropriate improvements to the
system to avoid undertaking inefficient or counterproductive revisions
to the Grants.gov system. Likewise, a FDP official told us face-to-
face meetings with grantor agency officials allow them to provide
input on proposed changes to grants management policies and practices.
In a second example, several state and local grantee association
officials referred to the communication channels that were set up
while implementing the Recovery Act as an example of effective two-way
communication they would like to see replicated. In the same letter
submitted to OMB after the creation of COFAR was announced, 10
organizations representing state and local officials referenced the
constant and consistent communication OMB and the Recovery Board
engaged in with members of the grantee community as a requirement for
success. We have also previously reported that OMB and Recovery Board
officials held weekly conference calls with state and local
representatives to hear comments, concerns, and suggestions from them
and share decisions.[Footnote 30] As a result of these calls, federal
officials changed their plans and related guidance. This type of
interaction was essential in clarifying federal intent, addressing
questions, and establishing working relationships for the
implementation efforts. However, several officials said these outreach
efforts have dwindled, and they again feel OMB is not involving them
in COFAR priority-setting discussions. Although the circumstances
surrounding the Recovery Act were unusual in that there was a high
level of funding available that had to be spent quickly, there are
opportunities for COFAR to learn what communication strategies worked
for agency officials and grantees, and apply those strategies.
Another possible mechanism for improving communication with states and
localities might be to use the Partnership Fund for Program Integrity
Innovation (Partnership Fund) as a venue for federal policymakers to
communicate and engage with the grantee community on proposed grants
management reforms. Established by the 2010 Consolidated
Appropriations Act, and administered by OMB, the Partnership Fund
allows federal, state, local, and tribal agencies to pilot innovative
ideas for improving assistance programs in a controlled environment.
We previously reported that as part of implementing the Partnership
Fund, OMB established a Federal Steering Committee, consisting of
senior policy officials from federal agencies that administer benefits
programs and formed the "Collaborative Forum."[Footnote 31] The
Collaborative Forum is made up of state representatives and
stakeholder experts, including federal agencies, nongovernmental
organizations, and others, who collaborate to generate, develop, and
consult on potential pilot projects. The forum's website, [hyperlink,
http://collaborativeforumonline.com], is used to hold discussions
about potential projects and to share lessons and best practices among
members.
Conclusions:
In a time of fiscal constraint, continuing to support the current
scope and breadth of federal grants to state and local governments
will be a challenge. Given this fiscal reality, it becomes more
important to design and implement grants management policies that
strike an appropriate balance between ensuring accountability for the
proper use of federal funds without increasing the complexity and cost
of grants administration for agencies and grantees. Duplicative,
unnecessarily burdensome, and conflicting grants management
requirements result in resources being directed to nonprogrammatic
activities, which could prevent the cost-effective delivery of
services at the local level. Streamlining and simplifying grants
management processes is critical to ensuring that federal funds are
reaching the programs and services Congress intended.
In October 2011, OMB created COFAR and tasked it with overseeing the
development of federal grants management policy. Although COFAR
recently identified some priorities, it has not yet released to the
public an implementation plan that includes performance targets,
mechanisms to monitor, evaluate, and report on progress made towards
stated goals, and goal leaders who can be held accountable for those
goals. Although OMB officials provided us with some additional and
updated information in their comment letter that we were unable to
assess or validate, they agreed with our recommendations that OMB and
COFAR need to develop an implementation schedule and mechanisms to
monitor, evaluate and report on results, clarify roles and
responsibilities for the various streamlining initiatives and
engagement with federal stakeholders, and develop an effective two-way
communication strategy that includes the grant recipient community.
OMB officials acknowledged that more needs to be done to clarify roles
and responsibilities and plans for moving forward with various
streamlining initiatives. Moreover, stakeholders continue to express
frustration about limited opportunities to provide feedback on
proposed reforms. If grantees remain isolated from COFAR's development
of new grants management systems and policies, those systems and
policies could be ineffective or require more resources to use.
Recommendations for Executive Action:
We recommend the Director of OMB, in collaboration with the members of
COFAR, take the following three actions:
1. Develop and make publicly available an implementation schedule that
includes performance targets, goal leaders who can be held accountable
for each goal, and mechanisms to monitor, evaluate, and report on
results.
2. Clarify the roles and responsibilities for various streamlining
initiatives and steps for decision making, in particular how COFAR
will engage with relevant grant-making agency stakeholders and utilize
agency resources.
3. Improve efforts to develop an effective two-way communication
strategy that includes the grant recipient community, smaller grant-
making agencies that are not members of COFAR, and other entities
involved with grants management policy.
Agency Comments and Our Evaluation:
We provided a draft of this report to OMB, Education, GSA, HHS, and
NSF for comment. NSF and HHS provided technical comments, which we
incorporated as appropriate. In its written comments, OMB generally
concurred with our findings and recommendations but also said there
had been significant progress on the grants management streamlining
process in recent months, including:
* using a more detailed project plan internally to monitor progress
made towards the priorities established for COFAR;
* making efforts to solicit the views of all federal agencies
including town hall meetings, formal circulation of draft policies for
comment prior to publication, and conference calls to share
information on key issues; and:
* using meetings, webinars, and teleconferences to inform a diverse
cross section of stakeholder groups about the work that the COFAR is
doing, and to get their feedback on upcoming policy changes.
Because OMB only provided us with additional and updated information
at the end of its comment period, we could neither verify nor validate
it. However, we have incorporated OMB's comments into the body of the
report, as appropriate, in order to make our review as up-to-date as
possible.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
Secretaries of Education, and Health and Human Services; Administrator
of GSA; Director of the National Science Foundation; the Director of
the Office of Management and Budget and to appropriate congressional
committees. The report also is available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff members have any questions or wish to discuss the
material in this report further, please contact me at (202) 512-6806
or czerwinskis@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this
report are listed in Appendix V.
Signed by:
Stanley J. Czerwinski:
Director, Strategic Issues:
[End of section]
Appendix I: Scope and Methodology:
We were asked to examine federal grants management reform efforts. To
accomplish this, we reviewed (1) what the Office of Management and
Budget (OMB) and other federal grants governance bodies have done
since the passage of P.L. 106-107 in 1999 to reform grants management
processes and reduce unnecessary burdens on applicants, grantees, and
federal agencies; and (2) what actions, if any, have been taken to
address what we have found to be persistent management challenges,
such as the lack of a comprehensive plan for implementing reforms,
confusion over roles and responsibilities among grants governance
bodies, and inconsistent two-way communication with stakeholders.
To address both objectives, we reviewed P.L. 106-107; and OMB
circulars and guidance such as OMB-12-01, "Creation of the Council on
Financial Assistance Reform," OMB A-102, "Grants and Cooperative
Agreements With State and Local Governments," and A-110, "Uniform
Administrative Requirements for Grants and Other Agreements with
Institutions of Higher Education, Hospitals and Other Non-Profit
Organizations," which describe administrative requirements for
different types of grantees, and OMB's February 2012 advanced notice
of proposed guidance, which proposes several ideas for circular
reforms.[Footnote 32] We also reviewed action plans created by former
and current interagency councils with responsibility for overseeing
grants management reforms, as well as our previous work and other
literature on grants management initiatives and the related challenges
that have undermined the government's ability to simplify grants
management processes, reduce unnecessary burden on applicants,
grantees, and federal agencies, and improve delivery of services to
the public. We also reviewed our previous work on collaborative
mechanisms and management consolidation efforts.
We interviewed officials from OMB who are involved with developing and
implementing government-wide grants management policy; officials at
the three agencies that served as consortia leads for the 2004 to 2012
Grants Management Line of Business (GMLOB) e-government initiative:
the National Science Foundation (NSF), Health and Human Services
(HHS), and the Department of Education; and officials at the agency
that managed the Financial Management Line of Business (FMLOB) e-
government initiative in 2012: the General Services Administration
(GSA). To capture the perspective of grantor agencies, we spoke to
officials from HHS, NSF, and the Department of Education in their
grant-making and administration capacities. To understand grantee
perspectives, we interviewed officials from grantee associations that
represent a variety of grantee types including state and local
governments, nonprofit organizations, and universities.
To select the grantee associations that we interviewed, we relied on
three data sources:
4. Our previous work on grant streamlining which included 31 grantee
associations separated into four categories: state government, local
and regional government, nonprofits, and tribal;
5. A list of grant associations included on the Grants.gov website;
and:
6. Additional grantee associations that have been active in grants-
related topics in the past.
We selected 16 grantee associations to contact. These associations
represented a variety of grantee types from state and local
government, nonprofit organizations, as well as associations
representing grantees on crosscutting grants related issues. In
addition, the associations could offer a historical perspective on
federal efforts to streamline grants management. Of the 16
associations we contacted, 8 associations said they were knowledgeable
about grants management reforms and could answer our questions. We
interviewed officials at these 8 associations:
* National Association of State Auditors, Comptrollers, and Treasurers:
* National Association of State Budget Officers:
* National Association of Regional Councils:
* National Association of Counties:
* National Grants Management Association:
* National Grants Partnership:
* Federal Demonstration Partnership:
* National Association of Chief Information Officers:
Two additional associations, Federal Funds Information for States and
National Council of Nonprofits, sent us comments on grants management
reforms in writing.
We conducted this performance audit from July 2012 to May 2013 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Table of Selected Grants Management Reforms:
Name of Initiative: The Federal Financial Assistance Management
Improvement Act of 1999 (Public Law 106-107);
Start date: 1999;
Type: Governance;
Content: To address grants management issues, the act required the
Office of Management and Budget (OMB) to direct, coordinate, and
assist federal agencies in establishing common grants management
systems, and simplifying their application, administrative, and
reporting procedures with the goal of improved efficiency and delivery
of services to the public. The law sunsetted in 2007.
Name of Initiative: Grants Policy Committee (GPC);
Start date: 1999;
Type: Governance;
Content: The Chief Financial Officers (CFO) Council established the
GPC to implement P.L. 106-107. Composed of grants policy experts from
across the federal government, the GPC oversaw the efforts of cross-
agency work groups focusing on different aspects of grants management,
recommended policies and practices to OMB, and coordinated related
interagency activities. OMB replaced the GPC in 2011 with the Council
on Financial Assistance Reform (COFAR).
Name of Initiative: Grants Executive Board (GEB);
Start date: 2002;
Type: Governance;
Content: This board consisted of senior officials from federal grant-
making agencies and provided strategic direction and oversight of
Grants.gov, a grant identification and application portal. OMB
coordinated grants management policy through the board and the GPC
until October 2011, when OMB announced that COFAR would replace both
of these federal grant bodies.
Name of Initiative: Grants.gov;
Start date: 2003;
Type: Process;
Content: In response to P.L. 106-107, OMB created Grants.gov, a
central grant identification and application website for federal grant
programs. The Grants.gov oversight and management structure includes
HHS, the managing partner agency, the Grants.gov Program Management
Office, which is housed within HHS and responsible for day-to-day
management, and formerly the GEB which provided leadership and
resources. The GPC was also involved because of its role in
streamlining pre-award policies and implementing P.L. 106-107.
Name of Initiative: Grants Management Line of Business (GMLOB);
Start date: 2004;
Type: Process;
Content: Established to support the development of a government-wide
solution to support end to-end grants management activities that
promote citizen access, customer service, and agency financial and
technical stewardship. In 2005, OMB selected the Department of Health
and Human Services (HHS) and the National Science Foundation (NSF) to
jointly lead the effort. Later, NSF took over the leadership role. In
fiscal year 2012, it became part of the Financial Management Line of
Business.
Name of Initiative: Federal Funding Accountability and Transparency
Act of 2006 (FFATA);
Start date: 2006;
Type: Transparency;
Content: This act required OMB to establish a free, publicly
accessible website containing data on federal awards and subawards.
OMB began providing data on federal awards on USAspending.gov in
December 2007 and phased in reporting on subawards in 2010.
Name of Initiative: American Recovery and Reinvestment Act of 2009
(Recovery Act);
Start date: 2009;
Type: Transparency;
Content: Congress and the administration built provisions (such as
quarterly use and outcome reporting) into the Recovery Act to increase
transparency and accountability over spending. The Recovery Act called
for a website (Recovery.gov) for the public to access reported data. A
second website (FederalReporting.gov) was established so grant
recipients could report their data. The Recovery Act also established
the Recovery Accountability and Transparency Board to coordinate and
conduct oversight of funds distributed under the act in order to
prevent fraud, waste, and abuse.
Name of Initiative: Government Accountability and Transparency Board
(GATB);
Start date: 2011;
Type: Transparency;
Content: This board, established by an executive order, provides
strategic direction for enhancing the transparency of federal spending
and advance efforts to detect and remediate fraud, waste, and abuse in
federal programs. It is charged to work closely with the existing
Recovery Board to extend its successes and lessons learned to all
federal spending.
Name of Initiative: Council on Financial Assistance Reform (COFAR);
Start date: 2011;
Type: Governance;
Content: This council replaced the GPC and GEB in October 2011. OMB
charged COFAR with identifying emerging issues, challenges, and
opportunities in grants management and policy and providing
recommendations to OMB on policies and actions to improve grants
administration. COFAR is also expected to serve as a clearinghouse of
information on innovations and best practices in grants management.
COFAR is made up of the OMB Controller and the Chief Financial
Officers from the largest eight grant-making agencies and one of the
smaller federal grant-making agencies. The latter serves a rotating 2-
year term.
Name of Initiative: Grants Circular Reforms;
Start date: 2012;
Type: Process;
Content: In February 2012, OMB published an advanced notice of
proposed guidance detailing a series of reform ideas that would
standardize information collection across agencies, adopt a risk-based
model for single audits, and provide new administrative approaches for
determining and monitoring the allocation of federal funds. After
receiving more than 350 public comments on its advanced notice of
proposed guidance, OMB published its circular reform proposal in
February 2013, and plans to implement the reforms by December 2013.
Name of Initiative: Grant Closeout Controller Alert;
Start date: 2012;
Type: Process;
Content: To improve the timeliness of grant close out and reduce
undisbursed balances, the Controller of OMB issued a "Controller
Alert" to all federal chief financial officers instructing agencies to
take appropriate action to closeout grants in a timely manner. It
provided a number of strategies such as establishing annual
performance targets for timely grant close out.
Source: GAO.
Legend:
Governance initiatives: Intended to make changes that affect policy
and oversight.
Process initiatives: Intended to simplify aspects of the grants life
cycle.
Transparency initiatives: Intended to increase the transparency of
information detailing federal awards and expenditures.
[End of table]
[End of section]
Appendix III: Grants Management Line of Business Consortia Leads and
Customers as of January 2013:
G5--Department of Education:
* Department of Education:
- Federal Student Aid:
- Institute of Education Sciences:
- Office of Chief Financial Officer:
- Office of the Deputy Secretary:
- Office of Elementary and Secondary Education:
- Office of Innovation and Improvement:
- Office of Legislation and Congressional Affairs:
- Office of Postsecondary Education:
- Office of Special Education and Rehabilitative Services:
- Office of Special Education Programs:
- Office of Vocational and Adult Education:
- Office of English Language Acquisition, Language Enhancement and
Academic Achievement for Limited English Proficient Students:
- Office of Planning, Evaluation and Policy Development:
- Risk Management Services:
Grantsolutions.com--Department of Health and Human Services:
* Department of Health and Human Services:
- Administration for Children and Families:
- Administration for Community Living:
- Center for Medicare & Medicaid Services & Office of Consumer
Information & Insurance Oversight:
- Health Resources & Services Administration:
- Indian Health Services:
- Assistant Secretary for Preparedness & Response:
- Office of Assistant Secretary for Health:
- Office of the National Coordinator:
* Department of State:
- Over 20 bureaus and programs:
* Department of Transportation:
- Federal Railways Administration:
- Federal Motor Carriers Administration:
- Pipelines and Hazardous Materials Safety Administration:
* United States Agency for International Development:
* Department of Treasury:
- Internal Revenue Service:
* Department of Homeland Security - U.S. Citizenship & Immigration
Service:
* Social Security Administration:
* Denali Commission:
Research.gov--National Science Foundation:
* National Science Foundation:
* National Aeronautics and Space Administration:
[End of section]
Appendix IV: Comments from the Office of Management and Budget:
Executive Office of The President:
Office of Management And Budget:
The Controller:
Washington, D.C. 20503:
April 29, 2013:
Mr. Stanley Czerwinski:
Director, Strategic Issues:
U.S. Government Accountability Office:
440 G Street, NW:
Washington, DC 20548:
Dear Mr. Czerwinski,
Thank you for the opportunity to comment on the draft report entitled
"Grants Management: Improved Planning, Coordination, and Communication
Needed to Strengthen Reform Efforts" (GAO 13-383). The Office of
Management and Budget (OMB) agrees with the objectives reflected in
GAO's recommendations to develop an implementation schedule and
mechanisms to monitor, evaluate and report on results, clarify roles
and responsibilities for various streamlining initiatives and
engagement with Federal stakeholders, and develop an effective two-way
communications strategy that includes the grant recipient community.
There has been significant progress on the grants streamlining process
in recent months, and OMB would like to ensure that GAO has complete
information, provided below, about all of the activities supporting
this initiative.
(1) Two-way stakeholder engagement is essential to the work of the
COFAR.
OMB strongly agrees with the emphasis placed by GAO on the importance
of two-way stakeholder engagement. The COFAR has a two-pronged
strategy for gathering and incorporating stakeholder feedback into its
efforts.
1. Establish mechanisms for stakeholders to provide feedback that are
equally available to all. OMB has made use of several venues for
dialogue with stakeholders that allow any interested entity —large or
small — to participate. These include the following:
1. Inviting public comment on the COFAR's policy deliverables. For the
COFAR's first deliverable there were two Notices published in the
Federal Register: an Advance Notice of Proposed Guidance (ANPG)
[Footnote 1] in February 2012 and a Notice of Proposed Guidance (the
proposal — published online and with notice in the Federal Register)
[Footnote 2] in February 2013. In response to the ANPG, OMB received
over 350 public comments. The ensuing proposal would, if adopted,
represent an overhaul of all government-wide guidance on grants and is
intended to reduce burden and risk of waste, fraud and abuse.
2. Maintaining a public website. The COFAR website is available at
cfo.gov/COFAR and provides information regarding the COFAR priorities,
deliverables with expected due dates and responsible entities for
accomplishment, and indicators of success. This website lists an email
address (COFAR [AT] omb.eop.gov) where any stakeholder may contact the
COFAR.
3. Live and recorded webcasts. OMB with the COFAR is conducting
webcasts (the first was held on February 8, 2013)[Footnote 3] where
representatives of large stakeholder organizations are able to engage
in a dialogue and an unlimited number of stakeholders can view the
events live and as a recording. (More than 2,600 viewers have watched
the recording of the first webcast.)
2. Engage in in-depth dialogues with interested stakeholder groups pro-
actively and upon request.
OMB leverages opportunities to address key stakeholder groups at
meetings, conferences, and on conference calls (as the draft report
suggests) and webcasts. The attached list provides a sample list of 25
of these opportunities since the publication of the proposal alone.
Although budget constraints prevent us from traveling to attend all of
these events, we often find alternative ways to participate remotely
when needed. These engagements include conversations with FDP (as
suggested in GAO's draft report), along with many others groups
representing Federal agencies; universities; state, local, and tribal
governments; nonprofits; and private industry, including the audit
community. In addition, OMB and the COFAR have worked to cultivate
relationships and opportunities for dialogue with groups of
stakeholders who may not have been aware of the COFAR's work
otherwise, such as the Council of Nonprofits and the United South and
Indian Tribes. As a snapshot of the types of engagements in which OMB
participates, please see the attached list of invitations for speaking
engagements OMB has accepted since February 2013.
This two-pronged approach is an attempt to address what OMB sees as a
fundamental challenge in stakeholder engagement in an area as broad
and sweeping as grant management policy: there are so many diverse
stakeholders that any policy creating a particular committee or select
consultative group of stakeholders would by definition leave others
out.
Despite all of this outreach, OMB recognizes that there may always be
a stakeholder or group of stakeholders who wish to be more involved or
who are not fully aware of all the work of the COFAR or of the nuances
of how work is progressing. OMB's objective in conducting outreach is
to ensure that stakeholders who are interested in contacting OMB or
the COFAR are able to do so, and that policies that are issued
demonstrate to stakeholders that their feedback has been heard.
While this strategy will continue to evolve over time, OMB has
received some feedback that indicates its efforts are proving
successful. OMB has received several email inquiries per week at the
COFAR email address, and as of April 2013 has responded to all of
them. More than 350 entities provided feedback in response to the
ANPG. More than 2,600 viewers have watched the webcast on grant reform
(a combination of both live and recorded viewings). In the webcast,
several of the participating stakeholders noted that though they may
not have agreed with all policies in the proposal, they could see that
their feedback had been incorporated. OMB will carefully evaluate the
feedback it receives in response to the proposal that is currently out
for comment, not just for the policy recommendations included but also
to evaluate how well the COFAR's proposal reflected the feedback
previously received. OMB looks forward to continuing to work with GAO
to ensure that we and the COFAR are doing the most we can to
incorporate stakeholder feedback throughout our policy development
process.
(2) Incorporating the views of all Federal grant-making agencies is
essential to the work of the COFAR.
The COFAR recognizes that in order for a select group of nine agencies
to successfully represent the entire Federal grant-making community,
there must be a pro-active effort to solicit the views of all Federal
agencies. As a result, in addition to the avenues for feedback
described above, the COFAR has made use of three further venues for
Federal agencies to engage:
1. Town Hall meetings with points of contact from each of the Federal
grant-making agencies. The COFAR has held three of these meetings
since its inception in October 2011, the first two of which were held
on August 28, 2012, and December 12, 2012. Summaries of these meetings
are available on the COFAR website at cfo.gov/COFAR. A third town hall
was held on April 23, 2013, and a written summary of the meeting will
be posted when available. The COFAR has not set a predetermined
frequency for these meetings in order to allow them to be held
whenever there are substantive policy issues requiring input and
interagency discussion.
2. Formal OMB circulation for comment of draft policies prior to
publication. Prior to the release of both the ANPG and the proposal
for reforming governmentwide guidance, OMB circulated these documents
for formal interagency review and comment. Including the interagency
comments OMB collected internally during the public comment period,
there have been a total of four opportunities to date for agencies to
comment on the draft policy, and OMB anticipates that any final reform
policy will be circulated for agency comment prior to being published.
3. Ad hoc conference calls in order to share information on particular
key issues. Since the establishment of the COFAR, OMB has periodically
hosted conference calls with grant-making agencies in order to share
information and discuss the status of various initiatives. For
example, such conference calls were held this past summer to solicit
agency feedback for the financial assistance community interagency
contributions to the funds for the Integrated Acquisition Environment
and System for Award Management.
4. A Rotating member that speaks with the voice of a smaller agency.
In addition to the permanent members of the COFAR, the COFAR includes
one seat that is held, on a rotating basis, by a smaller agency. The
expectation is that this rotating member will be able to represent the
views of small agencies by speaking from the perspective of a small
agency while relying on the COFAR staff centrally to gather input and
feedback from the broader collection of smaller agencies.
As with the strategy for engaging non-Federal stakeholders, OMB
recognizes that there may always be a Federal official or agency who
wishes to be more involved or who is not fully aware of all the work
of the COFAR or of the nuances of how work is progressing. In
evaluating whether engagement with Federal agencies is effective, OMB
seeks to answer similar questions to those offered for non-Federal
stakeholders above.
(3) To ensure that reforms are implemented effectively, the COFAR must
provide the public with clearly articulated deliverables, including
timelines and responsible entities for implementation and indicators
of success, and metrics to measure results.
When the COFAR was created in October 2011, its first goal was to
deliver on the directives of the President in Executive Order 13520,
Reducing Improper Payments and Eliminating Waste in Federal Programs
[Footnote 4] and a February 2011 Presidential Memorandum on
Administrative Flexibility, Lower Costs, and Better Results for State,
Local, and Tribal Governments.[Footnote 5] Given the momentous task of
overhauling governmentwide guidance governing grants management, the
COFAR focused exclusively on this initiative for the first year of its
work. As the COFAR made progress through the publication of the ANPG
and the development of the proposal published this February, it also
developed the broader internal control framework that supports grants
management.
The result of this work was a set of priorities that was announced at
the time of the new COFAR website in early February 2013. The slide
deck describing the priorities addresses:
* The challenge faced by the grants community that the COFAR will seek
to address;
* The proposed deliverables to address the challenge;
* Timelines for completion;
* Responsible entities for implementation;
* Expected return on investment of the initiative, as a mechanism to
evaluate results;
* Indicators of success, as further mechanisms to monitor results.
In addition to the information on these priorities that was made
public, OMB has used a more detailed project plan to monitor timelines
and roles and responsibilities internally, an example of which is
attached to this letter. As noted above, the past two and a half years
of COFAR work have been primarily devoted to implementation of the
first priority; the additional priorities are more nascent and will
encourage stakeholder engagement as they are refined (per the points
described above). The publicly-stated deliverables are intended to
leave room for further evolution of the right approach for
implementation.
OMB anticipates that as the work of the COFAR matures and the policy
outcomes of the initial priorities are closer to being finalized, the
COFAR will be better able to articulate metrics that allow for more
thorough evaluation of whether policy changes implemented are having
their intended impacts, thus providing evidence that can be used to
determine whether further changes are required and where future
priority areas of work may be.
(4) The Financial Management Line of Business (FMLOB) is managed by
the Treasury Department and supports implementation of Chief Financial
Officer Council and COFAR priorities.
OMB issued a Controller Alert on April 29, 2013 that announced that,
for Fiscal Year 2013, the Department of the Treasury (Treasury) will
serve as the managing partner for the Financial Management Line of
Business (FMLOB). In this role, Treasury will provide support to
partner agencies under the guidance and strategic direction of the
Chief Financial Officers Council (CFOC) and COFAR. OMB believes that
Treasury's key role in financial management governmentwide makes it
ideal to support implementation of financial management policies.
Treasury's Office of Financial Innovation and Transformation (FIT)
will serve as Managing Partner and the Program Management Office (PMO)
for the FMLOB. In accordance with OMB's guidance on shared services
(the Federal IT Shared Services Strategy)[Footnote 6], the Treasury's
FIT will lead efforts to transform Federal financial management,
reduce costs, increase transparency, and improve delivery of agencies'
missions by operating at scale, relying on common standards, shared
services, and using state-of-the-art technology.
Under the guidance of the CFOC, and COFAR, partner agencies will work
with the FMLOB's support to standardize core financial business
processes (including financial assistance) and data elements across
the Federal Government to provide: (1) reliable and accessible
financial data to the public; (2) adequate training and development
resources to agency workforces; and (3) strong oversight of Federal
programs using tools such as the Single Audit. The FMLOB will also
play a role in implementing OMB's Memorandum M-13-08, Improving
Financial Systems Through Shared Services. We anticipate that the
FMLOB's efforts will save Federal funds, improve public reporting of
Federal financial data, reduce administrative burdens, lower the risk
of waste, fraud and abuse, and significantly improve Federal financial
management services.
(5) Reducing administrative burden on recipients, including through
the use of standard data elements such as a standard format for grant
announcements, has long been and continues to be a priority under the
COFAR.
In 2004, OMB published Memorandum 04-01,[Footnote 7] requiring a
standard format for grants announcements on grants.gov. Since then,
building on work done under Public Law 106-107 to standardize all data
elements throughout the lifecycle of grants has continued to be a
priority of the community. In the ANPG and the proposal for reforming
grants policy, OMB refers to renewed policy emphasis in this area.
Further, with respect to announcements, the requirement to use a
standard format is included in section .204 of the proposal.
Requirements for standard applications are discussed in section .206
Standard Application Requirements, and standard reporting requirements
are discussed in section .505 Performance and Financial Monitoring and
Reporting. This idea is discussed more fully in the preamble document
summarizing the reforms. As discussed on the COFAR website, refining
implementation of these standard requirements is one of the COFAR's
priorities. As with all the COFAR priorities, this policy proposal was
developed in response to feedback received through the ANPG and other
stakeholder engagement venues described above.
In closing, OMB would submit that the most comprehensive single step
we could take to streamline grants management would be to finalize the
proposal published this past February. We would welcome any feedback
GAO or the Congress may have on the merits of the ideas described
therein. OMB agrees with the draft report's emphasis on the need for
defined deliverables and deep engagement with both Federal and non-
Federal stakeholders in order to ensure effective management of
Federal grants, and believes that significant progress has already
been made in this regard. We appreciate the opportunity to provide
additional information on the efforts OMB and the COFAR. We look
forward to working with GAO to ensure that these and other efforts
form a comprehensive approach to reducing administrative burden for
grant recipients while ensuring robust targeting of waste, fraud, and
abuse.
Thank you again for the opportunity to comment on the draft report. We
look forward to continuing our work together.
Sincerely,
Signed by:
Danny Werfel:
Controller:
Attachments:
November 2012 Internal Project Plan:
Sample List of Speaking Engagements:
Appendix IV Footnotes:
[1] ANPG and public comments received are available at [hyperlink,
http://www.regulations.gov/#!docketDetail;clerFR%252BPR%252BN%252B0%252B
SR%25213PS:rpn=25=-0;D=OMB-20l2-0002].
[2] The proposal and public comments received are available at:
[hyperlink, http://www.regulations.gov/#!docketGetail;D-OMB2013-0001].
[3] The Webcast may be viewed at: [hyperlink,
http://youtu.be/d1Zfb9ALBck].
[4] E0 13520 is available at: [hyperlink,
http://www.whitehouse.gov/the-press-office/executive-order-reducing-
improperpayments].
[5] The Presidential Memorandum is available at: [hyperlink,
http://www.whitehouse.gov/the-press-office/2011/02/28/presidential-
memorandum-administrative-flexibility].
[6] The Federal Information Technology Shared Services Strategy is
available at: [hyperlink,
http://www.whitehouse.gov/sites/default/files/omb/assets/egov_docs/share
d_services_strategy.pdf].
[7] M-04-01 OMB Issues Grants.gov FIND Policy is available here:
[hyperlink, http://www.whitehouse.gov/omb/memoranda_fy04_m04-01].
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Stanley J. Czerwinski, (202) 512-6806 or czerwinskis@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Thomas M. James, Assistant
Director, and Elizabeth Hosler, and Jessica Nierenberg, Analysts-in-
Charge, supervised the development of this report. Travis P. Hill,
Melanie Papasian, and Carol Patey made significant contributions to
all aspects of this report. Elizabeth Wood assisted with the design
and methodology, Amy Bowser provided legal counsel, Donna Miller
developed the report's graphics, and Susan E. Murphy and Sandra L.
Beattie verified the information in this report.
Other important contributors included Beryl Davis, Kim McGatlin, Joy
Booth, and James R. Sweetman, Jr.
[End of section]
Footnotes:
[1] For more information on the scale and scope of federal grant-
making activities, see GAO, Grants to State and Local Governments: An
Overview of Federal Funding Levels and Selected Challenges,
[hyperlink, http://www.gao.gov/products/GAO-12-1016] (Washington,
D.C.: Sept. 25, 2012).
[2] Constant dollar amounts reflect adjustments for inflation (e.g.,
the purchasing power of the $91 billion spent in 1980 represents about
$221 billion in fiscal year 2011 dollars).
[3] As defined in the act, "federal financial assistance" includes
grants, cooperative agreements, loans, loan guarantees, insurance,
interest subsidies, and other forms of assistance. Pub. L. No. 106-
107, §4,113 Stat. 1486 (Nov. 20, 1999), citing 31 U.S.C. 7501(a)(5).
The current streamlining efforts have focused on grants and
cooperative agreements. In our evaluation we have also limited our
assessment to grants and cooperative agreements and, for simplicity,
refer to them as grants.
[4] See GAO, Grants Management: Improving the Timeliness of Grant
Closeouts by Federal Agencies and Other Grants Management Challenges,
[hyperlink, http://www.gao.gov/products/GAO-12-704T] (Washington,
D.C.: July 25, 2012); Grants Management: Action Needed to Improve the
Timeliness of Grant Closeouts by Federal Agencies, [hyperlink,
http://www.gao.gov/products/GAO-12-360] (Washington, D.C.: Apr. 16,
2012); Grants.gov: Action Needed to Address Persistent Governance and
Funding Challenges, [hyperlink,
http://www.gao.gov/products/GAO-11-478] (Washington, D.C.: May 6,
2011); Grants Management: Grants.gov Has Systemic Weaknesses That
Require Attention, [hyperlink, http://www.gao.gov/products/GAO-09-589]
(Washington, D.C.: July 15, 2009); Grants Management: Grantees
Concerns with Efforts to Streamline and Simplify Processes,
[hyperlink, http://www.gao.gov/products/GAO-06-566] (Washington, D.C.:
July 28, 2006); Grants Management: Additional Actions Needed to
Streamline and Simplify Processes, [hyperlink,
http://www.gao.gov/products/GAO-05-335] (Washington, D.C.: Apr. 18,
2005); and [hyperlink, http://www.gao.gov/products/GAO-12-1016].
[5] OMB-12-01, "Creation of the Council on Financial Assistance
Reform", OMB A-102, "Grants and Cooperative Agreements With State and
Local Governments", and A-110, "Uniform Administrative Requirements
for Grants and Other Agreements with Institutions of Higher Education,
Hospitals and Other Non-Profit Organizations", which describe
administrative requirements for different types of grantees, and OMB's
February 12 Advance Notice of Proposed Guidance, which proposes
several ideas for circular reforms (77 Fed. Reg. 11,778).
[6] For this review, we interviewed and collected comments from
officials at the following organizations: National Association of
State Auditors, Comptrollers, and Treasurers, National Association of
State Budget Officers, National Association of Regional Councils ,
National Association of Counties , National Grants Management
Association , National Grants Partnership , Federal Demonstration
Partnership , National Council of Nonprofits, National Association of
Chief Information Officers , and Federal Funds Information for States .
[7] In 1971, OMB published standards for establishing consistency and
uniformity in the administration of grants and other types of
financial assistance to state and local governments and certain Indian
tribunals. The first circular was A-102, "Uniform Administrative
Requirements for Grants-In-Aid to State and Local Governments." In
1976, OMB published Circular No. A-110, "Grants and Agreements with
Institutions of Higher Education, Hospitals and Other Nonprofit
Organizations," 41 Fed. Reg. 32,016 (July 30, 1976). Other key
circulars and guidance include OMB Circulars No. A-21, A-87, A-122
establishing principles for determining costs applicable to grants,
contracts, and other agreements with educational institutions, state,
local, and tribal governments, and nonprofit organizations, and OMB
Circular A-133 setting forth standards for obtaining consistency and
uniformity among federal agencies for the audit of states, local
governments, and nonprofit organizations expending federal awards.
[8] See Government-wide Guidance for Grants and Agreements; Federal
Agency Regulations for Grants and Agreements, 69 Fed. Reg. 26,276 (May
11, 2004).
[9] OMB has not completed revisions for any of the OMB grants-related
circulars (administrative requirements, guidance related to costs, and
audit guidance) or the guidance on lobbying restrictions.
[10] OMB's effort is in response to Executive Order 13520, which
directed OMB to work with executive branch agencies; state, local, and
tribal governments; and other key stakeholders to evaluate potential
reforms to federal grants policies. See Exec. Order No. 13520,
Reducing Improper Payments and Eliminating Waste in Federal Programs,
74 Fed. Reg. 62,201 (Nov. 25, 2009).
[11] "Reform of Federal Policies Relating to Grants and Cooperative
Agreements: Cost Principles and Administrative Requirements (including
Single Audit Act)," Advance Notice of Proposed Guidance, 77 Fed. Reg.
11,778 (Feb. 28, 2012).
[12] "Reform of Federal Policies Relating to Grants and Cooperative
Agreements; Cost Principles and Administrative Requirements (Including
Single Audit Act)," Proposed Guidance, 78 Fed. Reg. 7282 (Feb. 1,
2013).
[13] Office of Management and Budget, Office of Federal Financial
Management Policy Directive on Financial Assistance Program
Announcements, Notice of Issuance of Final Policy Directive, 68 Fed.
Reg. 37,370 (June 23, 2003).
[14] [hyperlink, http://www.gao.gov/products/GAO-09-589] and
[hyperlink, http://www.gao.gov/products/GAO-11-478].
[15] U.S. Office of Management and Budget, Report to Congress on the
Benefits of the President's E-government Initiatives, Fiscal Year 2012
(Washington, D.C.: Mar. 19, 2012).
[16] M-12-13, OMB Fiscal Year 2014 Budget Guidance, (Washington, D.C.:
May 18, 2012).
[17] The Federal Information Technology Shared Services Strategy is
available at: [hyperlink,
http://www.whitehouse.gov/sites/default/files/omb/assets/egov_docs/share
d_services_strategy.pdf].
[18] GAO, Grants Management: Attention Needed to Address Undisbursed
Balances in Expired Grant Accounts, [hyperlink,
http://www.gao.gov/products/GAO-08-432] (Washington, D.C.: Aug. 29,
2008).
[19] [hyperlink, http://www.gao.gov/products/GAO-12-360].
[20] GAO, Managing for Results: Key Considerations for Implementing
Interagency Collaborative Mechanisms, [hyperlink,
http://www.gao.gov/products/GAO-12-1022] (Washington, D.C.: Sept. 27,
2012).
[21] GAO, Streamlining Government: Questions to Consider When
Evaluating Proposals to Consolidate Physical Infrastructure and
Management Functions, [hyperlink,
http://www.gao.gov/products/GAO-12-542] (Washington, D.C.: May 23,
2012).
[22] [hyperlink, http://www.gao.gov/products/GAO-12-542].
[23] See [hyperlink, https://cfo.gov/cofar/]. Also, on February 8,
2013, COFAR and members of the grant community held a webcast to
discuss in a roundtable format the proposed reforms and COFAR
priorities.
[24] [hyperlink, http://www.gao.gov/products/GAO-12-1022].
[25] The eight agencies that provide the largest amounts of financial
grants assistance and are permanent COFAR members are the Departments
of Agriculture, Education, Energy, Health and Human Services, Homeland
Security, Housing and Urban Development, Labor, and Transportation.
[26] [hyperlink, http://www.gao.gov/products/GAO-12-542]
[27] [hyperlink, http://www.gao.gov/products/GAO-06-566].
[28] Signatories to the letter include officials from the National
Governors Association, National Conference of State Legislatures,
Council of State Governments, National Association of Counties,
National League of Cities, U.S. Conference of Mayors, International
City/County Management Association, National Association of State
Auditors, Comptrollers, and Treasurers, National Association of State
Chief Information Officers, and National Association of State Budget
Officers.
[29] [hyperlink, http://www.gao.gov/products/GAO-GAO-06-566].
[30] [hyperlink, http://www.gao.gov/products/GAO-12-913T].
[31] GAO, Streamlining Government: Key Practices from Shared
Efficiency Initiatives Should Be Shared Governmentwide, [hyperlink,
http://www.gao.gov/products/GAO-11-908] (Washington, D.C.: Sept. 30,
2011).
[32] "Reform of Federal Policies Relating to Grants and Cooperative
Agreements: Cost Principles and Administrative Requirements (including
Single Audit Act)," Advance Notice of Proposed Guidance, 77 Fed. Reg.
11,778 (Feb. 28, 2012).
[End of section]
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